Sasless,
Looking at this from across a fairly big ditch, but knowing quite some about commercial arrangements between so called “Certificate holders” and other commercial “entities” I suggest that it must appear here that the main hue and cry is a demonstration of FAA having finally woken up to their responsibilities and are now conducting audits which should have been in train.
Had audits been a regular occurrence there would now be no need to tweak the inspection requirements as the relevant officers’ should have known their subject in a way that receivers of licences, both flying and engineering are supposed to know their subject matter before license issue.
To wit: - “After that comment period, the FAA will begin an inspection program that will examine management systems that ensure operational control at all Part 135 Certificate Holders.
The inspection program is an effort on the part of the FAA --identify the extent of the operational control issues---“
But especially get this bit,”to improve training for FAA inspectors”,
It is fair to say that warning has been given and any operator that does not have the message to have its house in order is not wanting to trade. However as they say:-
“They are very concerned about the various business models
*Only the Certificate Holder can exercise Operational Control, -- is the only authorized entity inspected by the FAA and eligible to conduct aviation operations for hire.”
Yerssir--- but , if anyone can find a Certificate Holder that does not have a commercial arrangement with a separate aircraft owner or leasing company, or perhaps engine or xmon or radionics leasing companies, ---- the list goes on ----perhaps also a contract pilot supply company, then they would be indeed a rare individual.
I suggest that the FAA should focus and with some alarm, more on arrangements between Certificate holders and “other “ entities involved, where there is NO commercial arrangement.
FAA further clarifies its knowledge gaps here:-
“How does corporate leadership manage what is going on across their entire operation from their headquarters to their base site;”
But this bit defies description: - seems like a lead pilot who is also the manager cannot fly??
“Can include management personnel at the hospital or base location (such as a lead pilot or base manager) that individual must meet the above qualifications and cannot be the pilot on duty (the management person must be someone other than the pilot).”
Finally FAA has said what their audit duties must focus on and what those of all other countries regulatory authorities are now and always have been:-
“On a flight (or series of flights, as in the case of flights undertaken while on a shift), the pilot in command (PIC) retains the authority to make tactical aviation decisions as long as those decisions are made within the parameters set forth by the certificate holder. The FAA has repeated several times that while the PIC may receive a flight request from medical or hospital personnel, his ability to fulfil that request is based solely on the policies, procedures, and standards prescribed by the certificate holder.”
There is no room for complacency of operators for sure, but neither is there any room whatever for smugness by the regulators in other countries, they should take a lead and do what the FAA is finally doing.
Any countries poor safety record must first lie at the regulators door. TK has adequately descibed the demographrics of the same situation in NZ in another thread. "NZ pilots pay"
TET